Environmental Resource Center — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh St., S.W. Special Programs Research ancl Washington, D.C. 20590 Administration NOV 29 2004 Ms. Pretlo V. Knight Ref. No. 04-0231 Senior Consultant 101 Center Pointe Drive Environmental Resource Center Cary, North Carolina 27513 Dear Ms. Knight: This responds to your September 7, 2004 letter requesting clarification on marking and shipping paper requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-187). Specifically, you ask for an explanation of the marking and shipping paper requirements for a hazardous materials shipment containing two or more inner packagings of different but compatible hazardous materials packed together in the same outer package. You describe the following scenario: a package contains the following inner packagings- a 1-gallon glass bottle of benzene, a 1-gallon glass bottle of acetone, a 1-gallon glass bottle of ethanol, and a 4-ounce plastic bottle of elemental mercury. It is your understanding that the outer package must bear the proper shipping names and identification numbers for each hazardous material in the inner packagings. It is also your understanding that the shipping paper must include a separate basic description for each hazardous material in the inner packagings. Your understanding is correct. Section 173.24(e) authorizes the shipment of a mixed content of hazardous materials in the same outer package provided the hazardous materials are marked with the proper shipping name and identification number and labeled in accordance compatible and will not react dangerously with each other. The outer package must be with Subpart E of Part 172 for each hazardous material contained therein. In addition, each hazardous material packaged in the outer package must also be properly described on the shipping paper in accordance with Subpart C of Part 172, including the number and type of packagings. I hope this arıswers your inquiry. Chief, Standards Development Office of Hazardous Materials Standards 173.24(E) 040231#

Page 2ENVIRONMENTAL RESOURCE CENTER® 101 Center Pointe Drive, Cary, North Carolina 27513 (919) 469-1585 Boothe Markus §173-241 September 7, 2004 Marking * Shipping Paper? 04-0231 Mr. Edward Mazzullo Director for the Office of Hazardous Materials Standards 400 7' S:reet SW US DOT RSPA (DH M10) Washington, DC 20590-0001 Dear Mr Mazzullo, According to 49 CFR 172.404(b), when two or more packages containing compatible container or overpack must be labeled as required for each class of hazardous material hazardous material are placed within the same outside container or overpack, the outside contained therein. However, the Hazardous Material Regulations do not seem to address the issues of marking or shipping paper requirements for such packages. What are the marking and shipping paper requirements for a hazardous materials shipment: with packagings that contain the following inner packages? • A 1-gallon glass bottle of benzene and a 1-gallon glass bottle of acetone • A 1-gallon glass bottle of ethanol and a 4-ounce plastic bottle of elemental mercury It is my understanding that the outer packagings must bear the proper shipping names and must include a separate basic description for each inner package. Are these assumptions the identification numbers for each inner package. I also assume that the shipping paper Additionally, are there any special statements required on the shipping paper when describing the type and quantity of such packaging as an overpack? I believe that marking and shipping paper requirements for overpacked compatible on the subject frequently. hazmats should be clarified in the Hazardous Material Regulations, as we receive questions I appreciate your time and help on this matter. Best regards, 'Hol Krued Ms. Pretlo V. Knight Senior Consultant ® Prided on Flecycled Paper#